^1. Case Concerning the Temple of Preah Vihear (Cambodia v. Thailand), Merits, [1962] I.C.J. Rep. 6 [hereinafter 1962 Judgment].

^2. CUASAY, Peter, “Borders on the Fantastic: Mimesis, Violence, and Landscape at the Temple of Preah Vihear” (1998) 32 Modern Asian Studies 849 at 849CrossRefGoogle Scholar.

^3. 16 November 1972, 1037 U.N.T.S. 151.

^4. Request for Interpretation of the Judgment of 15 June 1962 in the Case Concerning the Temple of Preah Vihear (Cambodia v. Thailand) (Cambodia v. Thailand), Judgment of 11 November 2013, [2013] I.C.J. Rep. 281 [hereinafter 2013 Judgment].

^5. For a broader analysis of the ICJ as an appropriate forum to deal with disputes concerning cultural resources or to ensure the enforcement of cultural heritage law, see CHECHI, Alessandro, The Settlement of International Cultural Heritage Disputes (Oxford: Oxford University Press, 2014)CrossRefGoogle Scholar.

^6. The term “global public good” is used in international law discourse to refer to values that are fundamental for the international community as a whole and that transcend the interests of individual states, such as peace, human and peoples’ rights, and biodiversity conservation. The idea of cultural heritage as a “global public good” can be traced back to the Convention for the Protection of Cultural Property in the Event of Armed Conflict, 14 May 1954, 249 U.N.T.S. 240 [hereinafter 1954 Convention], according to which “damage to cultural property belonging to any people whatsoever means damage to the cultural heritage of all mankind, since each people makes its contribution to the culture of the world” (preamble). See FRANCIONI, Francesco, “Public and Private in the International Protection of Global Cultural Goods” (2012) European Journal of International Law 719CrossRefGoogle Scholar; and GAJA, Giorgio, “The Protection of General Interests in the International Community” (2012) 364 Collected Courses of the Hague Academy of International Law 9 at 183–184Google Scholar.

^7. CANÇADO TRINDADE, Antônio Augusto, “International Law for Humankind: Towards a New Jus Gentium (I): General Course on Public International Law” (2005) 316 Collected Courses of The Hague Academy of International Law 9 at 318–319Google Scholar.

^8. BENZING, Markus, “Community Interests in the Procedure of International Courts and Tribunals” (2006) The Law and Practice of International Courts and Tribunals 369 at 374Google Scholar.

^9. POISSONNIER, Ghislain, “Préah Vihéar: le temple de la discorde” (2012) Journal du droit international 115Google Scholar.

^10. This corresponds to the crest of a hill or mountain range that separates neighbouring drainage basins, that is, the areas of land where surface water converges to a single point at a lower elevation.

^11. 1962 Judgment, supra note 1 at 21–3.

^12. Ibid., at 9.

^13. Ibid., at 36–7.

^14. Ibid., at 23. In their Dissenting Opinions, Judges Wellington Koo and Sir Percy Spender criticized the argument advanced by the Court that the Siamese authorities should have noticed that the Annex 1 map had awarded the Temple to Cambodia and should have lodged a formal protest with France. On the alleged acceptance of the Thai government, see also CHAN, Phil C.W., “Acquiescence/Estoppel in International Boundaries: Temple of Preah Vihear Revisited” (2004) Chinese Journal of International Law 421CrossRefGoogle Scholar.

^15. 1962 Judgment, supra note 1 at 36–7 (emphasis added).

^16. Also, it resulted from the maps submitted to UNESCO that Cambodia claimed not only the entire promontory of Preah Vihear, but also the hill of Phnom Trap, which Thailand claimed; 2013 Judgment, supra note 4, paras. 25–6.

^17. See WHC-08/32.COM/24Rev, Decision 32 COM 8B.102, 220–4.

^18. UN Secretary Council, “Security Council Press Statement on Cambodia-Thailand Border Situation”, SC/10174, 14 February 2011. The Security Council collaborated closely with the Association of Southeast Asian Nations (ASEAN). On the role of ASEAN in the Temple of Preah Vihear dispute, see PHAN, Hao Duy, “Institutional Design and Its Constraints: Explaining ASEAN’s Role in the Temple of Preah Vihear Dispute” (2015) 1 Asian Journal of International Law 7CrossRefGoogle Scholar.

^19. WHC-11/35.COM.INF.20, Summary Records, 214–19, at 216–17.

^20. Ibid., at 217. The Thai government went so far as to announce that it was determined to denounce the WHC. But the UNESCO Director-General never received the written instrument of denunciation.

^21. Request for Interpretation of the Judgment of 15 June 1962 in the Case concerning the Temple of Preah Vihear (Cambodia v. Thailand) (Cambodia v. Thailand), Provisional Measures, Order of 18 July 2011, [2011] I.C.J. Rep. 537 [hereinafter 2011 Order], paras. 10 and 48.

^22. Ibid., paras. 61–6, 69.

^23. The Court further held that the hill of Phnom Trap lay outside the disputed area. 2013 Judgment, supra note 4, para. 98.

^24. Ibid., paras. 81 and 85.

^25. Ibid., paras. 89–91.

^26. Ibid., para. 101.

^27. “The judgment is final and without appeal. In the event of dispute as to the meaning or scope of the judgment, the Court shall construe it upon the request of any party.”

^28. 2013 Judgment, supra note 4, paras. 32–3.

^29. Ibid., para. 34. It has been argued that the ICJ held that it was precluded from revising the 1962 Judgment in order to reinforce that original Judgment. See KATTAN, Victor, “The Ghosts of the Temple of Preah Vihear / Phra Viharn in the 2013 Judgment” (2015) 1 Asian Journal of International Law 16CrossRefGoogle Scholar.

^30. 2013 Judgment, supra note 4, para. 52.

^31. Ibid., para. 71. This issue was addressed as Thailand claimed that Cambodia’s request was inadmissible because its real purpose was not to clarify the 1962 Judgment but to obtain a ruling that Cambodia had not requested and that the ICJ had not issued in 1962: that the Annex I map line constitutes the Parties’ common frontier in the Temple area.

^32. “The real purpose of the request must be to obtain … [a] clarification of the meaning and the scope of what the Court has decided with binding force, and not to obtain an answer to questions not so decided. Any other construction of Article 60 of the Statute would nullify the provision of the article that the judgment is final and without appeal”. Ibid., para. 55.

^33. Art. 18 of the 1954 Convention and art. 2 common to the four Geneva Conventions of 1949 specify that they apply to all cases of “declared war or of any other armed conflict”, which may arise between two or more States Parties, even if the state of war is not recognized by one of them, and to “all cases of partial or total occupation of the territory of a High Contracting Party …”.

^34. 2011 Order, supra note 21, paras. 48–51. See also Poissonnier, supra note 9 at 125–7.

^35. See arts. 6(1) and 7, WHC.

^36. See CARDUCCI, Guido, “Articles 4–7. National and International Protection of the Cultural and Natural Heritage” in Francesco FRANCIONI (with the assistance of Federico LENZERINI), ed., The 1972 World Heritage Convention: A Commentary (Oxford: Oxford University Press, 2008), 103 at 113–115Google Scholar, 117–18.

^37. Federico LENZERINI, “Articles 30–3 and 35–8. Final Clauses” in Francioni, supra note 36, 345 at 348.

^38. LENZERINI, Federico, “Article 12. Protection of Properties Not Inscribed on the World Heritage List” in Francioni, supra note 36, 201 at 207Google Scholar.

^39. Carducci, supra note 36 at 125.

^40. MUSITELLI, Jean, “World Heritage, Between Universalism and Globalization” (2002) International Journal of Cultural Property 323Google Scholar.

^41. FORREST, Craig, International Law and the Protection of Cultural Heritage (Abingdon: Routledge, 2010), 278Google Scholar.

^42. See FRANCIONI, Francesco and LENZERINI, Federico, “The Future of the World Heritage Convention: Problems and Prospects” in Francioni, supra note 36, 401 at 402Google Scholar.

^43. In effect, as shown, art. 6(3) was mentioned by the ICJ in para. 106.

^44. This provision is restated in the Operational Guidelines for the Implementation of the WHC (WHC, 13/01, July 2013), paras. 179 and 182. Inscription on the Danger List allows expedited allocation of resources under the Fund (see arts. 15–18, WHC).

^45. Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of International Armed Conflict, 8 June 1977, 1125 U.N.T.S. 3 [hereinafter Protocol I]; and Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of Non-International Armed Conflicts, 8 June 1977, 1125 U.N.T.S. 609 [hereinafter Protocol II].

^46. See art. 53 of Protocol I, and art. 16 of Protocol II.

^47. See supra note 6. This treaty was built upon the Regulations Annexed to The Hague Convention (II) with Respect to the Laws and Customs of War on Land of 29 July 1899 ((1907) American Journal of International Law 66); and the Regulations Annexed to Hague Convention (IV) Respecting the Laws and Customs of War on Land of 18 October 1907 ((1908) American Journal of International Law 165).

^48. Art. 4(2) provides that the obligations contained in art. 4(1) can be waived “in cases where military necessity imperatively requires such a waiver”.

^49. See arts. 8(1) and (6). The International Register’s onerous requirements meant that it has never included more than a handful of properties. See UNESCO Doc. CLT/CIH/MCO/2008/PI/46 (2000), online: UNESCO <http://www.unesco.org/new/en/culture/themes/armed-conflict-and-heritage/the-hague-convention/>.

^50. Protocol for the Protection of Cultural Property in the Event of Armed Conflict, 14 May 1954, 249 U.N.T.S. 358.

^51. Second Protocol to the Convention for the Protection of Cultural Property in the Event of Armed Conflict, 26 March 1999, 38 I.L.M. 769 (1999).

^52. For an overview of the ICTY jurisprudence concerning cultural heritage, see LENZERINI, Federico, “The Role of International and Mixed Criminal Courts in the Enforcement of International Norms Concerning the Protection of Cultural Heritage” in Federico FRANCIONI and James GORDLEY, eds., Enforcing Cultural Heritage Law (Oxford: Oxford University Press, 2013), 40CrossRefGoogle Scholar; and FRULLI, Micaela, “Advancing the Protection of Cultural Property Through the Implementation of Individual Criminal Responsibility: The Case-Law of the International Criminal Tribunal for the Former Yugoslavia” (2005) Italian Yearbook of International Law 195Google Scholar.

^53. See e.g. Prosecutor v. Jokić, 18 March 2004, [2004] IT-01-42/1-S; and Prosecutor v. Strugar, 31 January 2005, [2005] IT-01-42-PT.

^54. Ibid., para. 53. Of course, this jurisprudence is limited in that it concerns situations where the protection of cultural heritage is subjected to the concept of military necessity and the distinction between military and non-military objectives. In this respect see FRANCIONI, Francesco, “Beyond State Sovereignty: The Protection of Cultural Heritage as a Shared Interest of Humanity” (2003–04) Michigan Journal of International Law 1209 at 1219Google Scholar.

^55. The ECCC were established with the Agreement Between the United Nations and the Royal Government of Cambodia Concerning the Prosecution under Cambodian Law of Crimes Committed During the Period of Democratic Kampuchea, 6 June 2003, online: ECCC <http://www.eccc.gov.kh/en/document/legal/agreement>. The ECCC consist of a national court composed of both national and international judges which has the competence to prosecute members of the Khmer Rouge for serious violations of Cambodian criminal law and international law.

^56. Closing Order (Indictment) in Case 002, concerning Noun Chea, Ieng Sary, Khieu Samphan and Ieng Thirith, paras. 1317, online: ECCC <http://www.eccc.gov.kh/en/case/topic/2>.

^57. Ibid., paras. 210, 321, 740–56, 1420-1.

^58. On this issue, see Chechi, supra note 5 at 256–8, 267–70.

^59. For instance, the ICTY has affirmed in various occasions that art. 3(d) of the ICTY Statute is a rule of humanitarian law that reflects customary international law (see Strugar, supra note 53), and that the Regulations annexed to the 1907 Hague Convention (supra note 47) as well as the 1954 Convention belong to customary international law (see Prosecutor v. Kordic & Cerkez, 26 February 2001, [2001] IT-95-14/2-T, para. 206; and Prosecutor v. Tadić, 2 October 1995, [1995] IT-94-1-I, para. 98).

^60. See e.g. SCOVAZZI, Tullio, “Diviser c’est détruire: Ethical Principles and Legal Rules in the Field of Return of Cultural Properties” (2010) Rivista di diritto internazionale 341 at 351Google Scholar; SANDHOLTZ, Wayne, Prohibiting Plunder. How Norms Change (Oxford: Oxford University Press, 2007), 223 at 256–257CrossRefGoogle Scholar; and FRANCIONI, Francesco, “Au-delà des traités: l’émergence d’un nouveau droit coutumier pour la protection du patrimoine culturel” (2007) Revue Générale de Droit International Public 19 at 29Google Scholar.

^61. The ICC Statute defines as war crimes the “[e]xtensive destruction and appropriation of property, not justified by military necessity and carried out unlawfully and wantonly” (art. 8(2)(a)(iv)). Additionally, arts. 8(2)(b)(ix) and 8(2)(e)(iv) classify as war crimes the “[i]ntentionally directing [of] attacks against buildings dedicated to religion, education, art, science or charitable purposes, historic monuments … provided they are not military objectives” with regard to international and non-international armed conflicts, respectively.

^62. ICC Statute, arts. 11 and 12.

^63. ICC, “ICC Prosecutor Opens Investigation into War Crimes in Mali: ‘The Legal Requirements Have Been Met. We Will Investigate’” (16 January 2013) ICC-OTP-20130116-PR869, online: ICC <http://www.icc-cpi.int/en_menus/icc/press%20and%20media/press%20releases/news%20and%20highlights/Pages/pr869.aspx>.

^64. ICC, “ICC Prosecutor Fatou Bensouda on the Malian State Referral of the Situation in Mali Since January 2012” (18 July 2012) ICC-OTP-20120718-PR829, online: ICC <http://www.icc-cpi.int/en_menus/icc/press%20and%20media/press%20releases/news%20and%20highlights/Pages/pr829.aspx>.

^65. Poissonnier, supra note 9 at 116–17.

^66. Request for Interpretation of the Judgment of 15 June 1962 in the Case Concerning the Temple of Preah Vihear (Cambodia v. Thailand), Judgment of 13 November 2013, Separate Opinion of Judge Cançado Trindade, para. 65 (emphasis in the original).

^67. Request for Interpretation of the Judgment of 15 June 1962 in the Case Concerning the Temple of Preah Vihear (Cambodia v. Thailand), Provisional Measures, Order of 18 July 2011, Separate Opinion of Judge Cançado Trindade. Here the Judge praised the creation of the provisional demilitarized zone: “[The] reassuring effects [of the provisional demilitarized zone] … are that they do extend protection not only to the territorial zone at issue, but also … to the life and personal integrity of human beings who live or happen to be in that zone or near it, as well as to the Temple of Preah Vihear itself … and all that the Temple represents” (para. 66).

^68. Ibid., paras. 96–100.

^69. Ibid., para. 113.

^70. Ibid., para. 115 (emphasis in the original).

^71. Second and third preambular paragraphs.

^72. “Without prejudice to the provisions of the [1954 Convention] and of other relevant international instruments, it is prohibited: (a) to commit any acts of hostility directed against the historic monuments, works of art or places of worship which constitute the cultural or spiritual heritage of peoples” (emphasis added).

^73. “Without prejudice to the provisions of the [1954 Convention], it is prohibited to commit any acts of hostility directed against historic monuments, works of art or places of worship which constitute the cultural or spiritual heritage of peoples” (emphasis added).

^74. 17 October 2003.

^75. Prosecutor v. Jokić, supra note 53, paras. 46 and 51.

^76. Ibid., para. 51.

^77. Prosecutor v. Strugar, supra note 53.

^78. Ibid., para. 232.

^79. Prosecutor v. Hadžihasanović & Kubura, 15 March 2006, IT-01-47, para. 63.

^80. Lenzerini, supra notes 52, 53.

^81. See supra note 31 and related text.

^82. “The decision of the Court has no binding force except between the parties and in respect of that particular case.”

^83. See BERMAN, Franklin, “The International Court of Justice as an ‘Agent’ of Legal Development?” in Christian J. TAMS and James SLOAN, eds., The Development of International Law by the International Court of Justice (Oxford: Oxford University Press, 2013), 7CrossRefGoogle Scholar.

^84. HENCKAERTS, Jean-Marie and DOSWALD-BECK, Louise, eds., Customary International Humanitarian Law. Practice, Vol. II, Part 1 (Cambridge: Cambridge University Press, 2005) 730CrossRefGoogle Scholar.

^85. ZAGATO, Lauso, “La protezione dei beni culturali nei conflitti armati: il rapporto tra diritto generale e accordo nel solco del secondo Protocollo 1999” in Alberico Gentili, La salvaguardia dei beni culturali nel diritto internazionale, Atti del Convegno, 22–23 settembre 2006 (San Ginesio: Centro internazionale di studi Gentiliani, 2008), 341 at 362Google Scholar. This author underlines that during the Vietnam War the US avoided bombarding the sites of Angkhor (Cambodia) and Hué (in the then North Vietnam), whilst during the Gulf Wars no state resorted to the derogation of military necessity to target the sites of Ur and Nineveh. On the conduct of hostilities by coalition forces during the First Gulf War, see also Sandholtz, supra note 60 at 194–6.

^86. LAUTERPACHT, Hersch, The Development of International Law by the International Court (New York: Stevens & Sons, 1958) 4Google Scholar.

^87. On the Court’s meagre case-law on cultural rights, see POLYMENOPOULOU, Eleni, “Cultural Rights in the Case Law of the International Court of Justice” (2014) Leiden Journal of International Law 447CrossRefGoogle Scholar.

^88. Application of the International Convention on the Elimination of All Forms of Racial Discrimination (Georgia v. Russian Federation), Preliminary Objections, Judgment of 1 April 2011. The ICJ held that it did not have jurisdiction over the merits of the case because Georgia had not met the procedural precondition for ICJ jurisdiction under art. 22 of the Convention on the Elimination of All Forms of Racial Discrimination (CERD), which required Georgia to negotiate with Russia regarding their dispute under CERD or to resort to CERD procedures prior to initiating proceedings at the ICJ (paras. 167–83).

^89. Memorial of Georgia, Vol. 1, 2 September 2009, para. 3.83.

^90. Certain Property (Liechtenstein v. Germany), Preliminary Objections, Judgment of 10 February 2005. The Prince of Liechtenstein also lodged an—unsuccessful—application with the European Court of Human Rights: Prince Hans-Adam II of Liechtenstein v. Germany, Application no 42527/98, Decision of 12 July 2001.

^91. The ICJ dismissed the action for lack of jurisdiction ratione temporis because the European Convention for the Peaceful Settlement of Disputes, 29 April 1957, E.T.S. No. 23, upon which Liechtenstein based the Court’s jurisdiction, entered into force between the two states only in 1980, i.e. long after the time when the cause of action accrued.

^92. Case Concerning the Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and Herzegovina v. Serbia and Montenegro), Judgment of 26 February 2007.

^93. Ibid., paras. 335–44. Moreover, the ICJ endorsed the observation made by the ICTY Trial Chamber in Krstić (Judgment of 2 August 2001, IT-98-33-T, para. 580): “where there is physical or biological destruction there are often simultaneous attacks on the cultural and religious property and symbols of the targeted group as well, attacks which may legitimately be considered as evidence of an intent to physically destroy the group.”

^94. Case Concerning the Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Croatia v. Serbia), Judgment of 3 February 2015, paras. 386–90.

^95. Jurisdictional Immunities of the State (Germany v. Italy: Greece Intervening), Judgment of 3 February 2012.

^96. Ibid., paras. 109–20.

^97. 2 December 2004, 44 I.L.M. 801 (2005), not yet in force.

^98. “The following categories … of property of a State shall not be considered as property specifically in use or intended for use by the State for other than government non-commercial purposes under article 19, subparagraph (c): … (d) property forming part of the cultural heritage of the State or part of its archives and not placed or intended to be placed on sale; (e) property forming part of an exhibition of objects of scientific, cultural or historical interest and not placed or intended to be placed on sale.”

^99. Legality of the Threat or Use of Nuclear Weapons, Advisory Opinion, Separate Opinion of Judge Weeramantry, [1996] I.C.J. Rep. 226 at 429.

^100. Ibid., 466–7.

^101. Accordance with International Law of the Unilateral Declaration of Independence in Respect of Kosovo, Advisory Opinion of 22 July 2010.

^102. Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory, Advisory Opinion of 9 July 2004.

^103. See, respectively, Written Contribution of the Authors of the Unilateral Declaration of Independence Regarding the Written Statements of 17 July 2009 (paras. 2.28, 3.34–3.35); and Written Statement Submitted by Palestine of 29 January 2004 (paras. 333–7).

^104. In this respect see also CHESTERMAN, Simon, “The International Court of Justice in Asia: Interpreting the Temple of Preah Vihear Case” (2015) 1 Asian Journal of International Law 1CrossRefGoogle Scholar.

^105. LAUTERPACHT, Elihu, “Principles of Procedure in International Litigation” (2009) Collected Courses of The Hague Academy of International Law 345 at 485Google Scholar.

^106. COGAN, Jacob KATZ, “Competition and Control in International Adjudication” (2008) Virginia Journal of International Law 411 at 419–426Google Scholar.

^107. Francioni, , supra note 54 at 1221Google Scholar.

^108. FRANCIONI, Francesco, “The Human Dimension of International Cultural Heritage Law: An Introduction” (2011) European Journal of International Law 9 at 10Google Scholar.

^109. Lenzerini, , supra note 52 at 45–46Google Scholar.

^110. At all events, Cambodia was a party to all the above-mentioned treaties, whereas Thailand has still to ratify the Additional Protocols of 1977 (supra note 45) and the Second Protocol of 1999 (supra note 51): see online: ICRC <http://www.icrc.org/applic/ihl/ihl.nsf/vwTreatiesByCountry.xsp>. However, the obligations contained in the Additional Protocols can be imposed upon states as a matter of general international law.

^111. See CHAMBERLAIN, Kevin, War and Cultural Heritage (Leicester: Institute of Art and Law, 2004) at 35–39Google Scholar, 47–51; and CARSTEN, Anne-Marie, “The International Legal Protection of World Heritage Sites During Armed Conflict” (2013) 5 Transnational Dispute ManagementGoogle Scholar, online: Transnational Dispute Management <http://www.transnational-dispute-management.com/article.asp?key=1996>.

^112. CARDUCCI, Guido, “The 1972 World Heritage Convention in the Framework of other UNESCO Conventions on Cultural Heritage” in Francioni, supra note 36, 363 at 365–367Google Scholar.

^113. It must also be considered that the definition of property protected by the WHC is narrower than that given in the 1954 Convention as the former is only concerned with immovable property.

^114. Chamberlain, supra note 111 at 30.

^115. Pursuant to art. 12, the Parties to a conflict must ensure the immunity of the property under “enhanced protection” by refraining from making it the object of attack or from any use of the property or its immediate surroundings in support of military action.

^116. Operational Guidelines for the Implementation of the WHC, supra note 44, para. 41.

^117. Guidelines for the Implementation of the 1999 Second Protocol to The Hague Convention of 1954 for the Protection of Cultural Property in the Event of Armed Conflict, 22 March 2012, CLT-09/CONF/219/3 REV. 4, paras. 36, 14.

^118. Decision 7.COM 3, online: UNESCO <http://www.unesco.org/new/en/culture/themes/armed-conflict-and-heritage/synergies/>, para. 3.

^119. Decision 7.COM 6, online: <http://www.unesco.org/new/en/culture/themes/armed-conflict-and-heritage/synergies/>, paras. 4–5.

^120. See online: UNESCO <http://www.unesco.org/new/en/culture/themes/armed-conflict-and-heritage/synergies/>.

^121. Only five states have requested the granting of enhanced protection: Azerbaijan, Belgium, Cyprus, Italy, and Lithuania. See online: UNESCO <http://www.unesco.org/new/en/culture/themes/armed-conflict-and-heritage/protection-of-cultural-property/enhanced-protection/>.

^122. See supra note 53 and related text.

^123. See GONZALEZ, Ariel W., “Great Expectations? Towards an Effective Application of the Regime of Enhanced Protection in the Second Protocol to the Hague Convention on the Protection of Cultural Property in the Event of Armed Conflict” in Nout Van WOUDENBERG and Liesbeth LIJNZAAD, eds., Protection of Cultural Property in Armed Conflict (The Hague: Martinus Nijhoff Publishers, 2010), 59 at 61–65Google Scholar.

^124. Francioni, supra note 6.

^125. The establishment of an International Coordinating Committee was requested in 2008 by the WHC Committee at its 32nd session (Quebec City) with Decision 32 COM 8B 102 (para. 14).

^126. At the time of writing, tourists are allowed at the site, which is no longer guarded by armed soldiers, thanks to an increase in transportation facilities in both countries. This is according to personal communication with a public servant of the Office of the Council of Ministers of the Thai government.

^127. See ROTH, William, “Temple Dispute: A Way Out of the Impasse” (22 July 2008)Google Scholar Bangkok Post, online: Bangkok Post <http://ki-media.blogspot.ch/2008/07/temple-dispute-way-out-of-impasse.html>.